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Privacy Policy

This Privacy Policy describes how K7 ARC, a Texas limited liability company (“K7 ARC,” “we,” “us,” or “our”), collects, uses, and shares information through the website located at k7arc.com (the “Website”).

Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through the Website (or third-party services employed on the Website), which can include: the IP addresses or domain names of the computers utilized by users, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the time spent on each page within the Website, the path followed within the Website, and other parameters about the device operating system and/or the user’s IT environment.

User

The individual using the Website who, unless otherwise specified, coincides with the data subject.

Data Subject

The natural person to whom the personal data refers.

Data Processor

The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller, as described in this Privacy Policy.

Data Controller

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of the Website. The data controller, unless otherwise specified, is K7 ARC.

This Website

The means by which the personal data of the user is collected and processed.

Service

The service provided by the Website as described in the relevant terms (if available) and on this site.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookies

Small sets of data stored in the user’s device.

Legal Information

This Privacy Policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This Privacy Policy relates solely to the Website, unless stated otherwise within this document.

Types of Data Collected

Among the types of personal data that the Website collects, by itself or through third parties, there are: cookies, username, email address, various types of data, usage data, website, first name, and last name. Complete details on each type of personal data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the data collection. Personal data may be freely provided by the user, or, in the case of usage data, collected automatically when using the Website. Unless specified otherwise, all data requested by the Website is mandatory, and failure to provide it may make it impossible for the Website to provide its services. Where the Website specifically states that some data is not mandatory, users are free not to communicate that data without consequences to the availability or functioning of the service. Users who are uncertain about which personal data is mandatory are welcome to contact K7 ARC. Any use of cookies — or of other tracking tools — by the Website or by the owners of third-party services used by the Website serves the purpose of providing the service required by the user, in addition to any other purposes described in this document and in the Cookie Policy. Users are responsible for any third-party personal data obtained, published, or shared through the Website and confirm that they have the third party’s consent to provide the data to us.

Mode and Place of Processing the Data

Methods of Processing

K7 ARC takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to K7 ARC, in some cases the data may be accessible to certain types of external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies) appointed, if necessary, as data processors. The updated list of these parties may be requested from K7 ARC at any time through the contact form on our Partner With Us page.

Legal Basis of Processing

K7 ARC may process personal data relating to users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: under some legislations, K7 ARC may be allowed to process personal data until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the legal bases below. This does not apply, however, whenever the processing of personal data is subject to European data protection law.
  • Provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof.
  • Processing is necessary for compliance with a legal obligation to which K7 ARC is subject.
  • Processing is related to a task carried out in the public interest or in the exercise of official authority vested in K7 ARC.
  • Processing is necessary for the purposes of the legitimate interests pursued by K7 ARC or by a third party.

K7 ARC will gladly help clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

Depending on the user’s location, data transfers may involve transferring data to a country other than their own. To find out more about the place of processing of such transferred data, users can check the relevant sections of this document. Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union, or to any international organization governed by public international law or set up by two or more countries, and about the security measures taken by K7 ARC to safeguard their data. If any such transfer takes place, users can find out more by contacting K7 ARC using the contact form on our Partner With Us page.

Retention Time

Personal data shall be processed and stored for as long as required by the purpose it has been collected for. Personal data collected for purposes related to the performance of a contract between K7 ARC and the user shall be retained until such contract has been fully performed. Personal data collected for the purposes of K7 ARC legitimate interests shall be retained as long as needed to fulfill such purposes. K7 ARC may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as consent is not withdrawn. K7 ARC may also be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes of Processing

Data concerning the user is collected to allow K7 ARC to provide its services, as well as for the following purposes: traffic optimization and distribution, hosting and backend infrastructure, registration and authentication, analytics, displaying content from external platforms, managing contacts and sending messages, contacting the user, managing support and contact requests, content commenting, spam protection, and remarketing and behavioral targeting. Users can find further detailed information about these purposes of processing and about the specific personal data used for each purpose in the sections below.

Detailed Information on the Processing of Personal Data

Personal data is collected for the following purposes and using the following services.

Analytics

The services in this section enable K7 ARC to monitor and analyze web traffic and can be used to keep track of user behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of the Website, to prepare reports on its activities, and to share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy PolicyOpt Out.

Contacting the User

Mailing List or Newsletter (This Website)

By registering on the mailing list or for the newsletter, the user’s email address will be added to the contact list of those who may receive email messages containing information of a commercial or promotional nature concerning the Website. The user’s email address might also be added to this list as a result of signing up to the Website or after making an inquiry.

Personal Data collected: email address.

Contact Form (This Website)

By filling in the contact form with their data, the user authorizes the Website to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.

Personal Data collected: email address, first name, and last name.

Content Commenting

Content commenting services allow users to make and publish their comments on the content of the Website. Depending on the settings chosen by K7 ARC, users may also leave anonymous comments. If there is an email address among the personal data provided by a user, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when users do not use the content commenting service.

Comment System Managed Directly (This Website)

The Website has its own internal content comment system.

Personal Data collected: email address, username, and website.

Displaying Content From External Platforms

This type of service allows the Website to incorporate content hosted on external platforms directly onto its pages and to interact with it. This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows the Website to incorporate content of this kind on its pages.

Personal Data collected: usage data and various types of data as specified in the privacy policy of the service. Place of processing: US — Privacy Policy.

Google Maps Widget (Google Inc.)

Google Maps is a maps visualization service provided by Google Inc. that allows the Website to incorporate content of this kind on its pages.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy Policy.

Gravatar (Automattic Inc.)

Gravatar is an image visualization service provided by Automattic Inc. that allows the Website to incorporate content of this kind on its pages. If Gravatar images are used for comment forms, the commenter’s email address (or part of it) may be sent to Gravatar, even if the commenter has not signed up for that service.

Personal Data collected: email address and usage data. Place of processing: US — Privacy Policy.

Instagram Widget (Instagram, Inc.)

Instagram is an image visualization service provided by Instagram, Inc. that allows the Website to incorporate content of this kind on its pages.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy Policy.

Vimeo Video (Vimeo, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC that allows the Website to incorporate content of this kind on its pages.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy Policy.

YouTube Video Widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows the Website to incorporate content of this kind on its pages.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy Policy.

Hosting and Backend Infrastructure

This type of service hosts data and files that enable the Website to run and be distributed, and provides a ready-made infrastructure to run specific features or parts of the Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where personal data is stored.

DigitalOcean (DigitalOcean, Inc.)

DigitalOcean is a hosting service provided by DigitalOcean, Inc.

Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: US — Privacy Policy.

OVH

OVH is a hosting service provided by OVH Canada.

Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: Canada — Privacy Policy.

Managing Contacts and Sending Messages

This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with the user. These services may also collect data concerning the date and time when a message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.

MailChimp (The Rocket Science Group, LLC)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: email address. Place of processing: US — Privacy Policy.

Managing Support and Contact Requests

This type of service allows the Website to manage support and contact requests received via email or by other means, such as the contact form. The personal data processed depends on the information provided by the user in the messages and the means used for communication (e.g., email address).

Ticksy

Ticksy is a support and contact request management service provided by Ticksy Limited.

Personal Data collected: various types of data as specified in the privacy policy of the service. Place of processing: Malta — Privacy Policy.

Registration and Authentication

By registering or authenticating, users allow the Website to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, the Website will be able to access some data stored by these third-party services, for registration or identification purposes.

Direct Registration (This Website)

The user registers by filling out the registration form and providing personal data directly to the Website.

Personal Data collected: email address, username, and various types of data.

Remarketing and Behavioral Targeting

This type of service allows the Website and its partners to inform, optimize, and serve advertising based on past use of the Website by the user. This activity is performed by tracking usage data and by using cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt-out offered by any of the services below, the user may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Google AdWords Remarketing (Google Inc.)

Google AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of the Website with the Google advertising network.

Personal Data collected: cookies and usage data. Place of processing: US — Privacy PolicyOpt Out.

Traffic Optimization and Distribution

This type of service allows the Website to distribute its content using servers located across different countries and to optimize performance. Which personal data is processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between the Website and the user’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which content that may contain personal information is transferred.

MaxCDN (NETDNA, LLC)

MaxCDN is a traffic optimization and distribution service provided by NETDNA, LLC. The way MaxCDN is integrated means that it filters all traffic through the Website — i.e., communication between the Website and the user’s browser — while also allowing analytical data from the Website to be collected.

Personal Data collected: cookies and various types of data as specified in the privacy policy of the service. Place of processing: US — Privacy Policy.

The Rights of Users

Users may exercise certain rights regarding their data processed by K7 ARC. In particular, users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given consent to the processing of their personal data.
  • Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.
  • Access their data. Users have the right to learn whether data is being processed by K7 ARC, obtain disclosure regarding aspects of the processing, and obtain a copy of the data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
  • Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data, in which case K7 ARC will not process it for any purpose other than storing it.
  • Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from K7 ARC.
  • Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format, and, where technically feasible, to have it transmitted to another controller without hindrance, provided the processing is based on consent or a contract and carried out by automated means.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details About the Right to Object to Processing

Where personal data is processed for a public interest, in the exercise of an official authority vested in K7 ARC, or for the purposes of the legitimate interests pursued by K7 ARC, users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.

How to Exercise These Rights

Any requests to exercise user rights can be directed to K7 ARC through the contact form on our Partner With Us page. Such requests can be exercised free of charge and will be addressed as early as possible and always within one month.

Cookie Policy

The Website uses cookies. To learn more, see the full Cookie Policy, published as part of our Terms of Use.

Additional Information About Data Collection and Processing

Legal Action

A user’s personal data may be used for legal purposes by K7 ARC in court or in the stages leading to possible legal action arising from improper use of the Website or the related services. The user acknowledges that K7 ARC may be required to reveal personal data upon request of public authorities.

Additional Information About User’s Personal Data

In addition to the information contained in this Privacy Policy, the Website may provide users with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

System Logs and Maintenance

For operation and maintenance purposes, the Website and any third-party services may collect files that record interaction with the Website (system logs), using other personal data (such as the IP address) for this purpose.

Information Not Contained in This Policy

More details concerning the collection or processing of personal data may be requested from K7 ARC at any time via the contact form on our Partner With Us page.

How “Do Not Track” Requests Are Handled

The Website does not support “Do Not Track” requests. To determine whether any third-party services it uses honor “Do Not Track” requests, please read their respective privacy policies.

Changes to This Privacy Policy

K7 ARC reserves the right to make changes to this Privacy Policy at any time by giving notice to users on this page and, where technically and legally feasible, by sending a notice to users via any contact information available to K7 ARC. It is strongly recommended to check this page often. If a user objects to any changes to the policy, the user must cease using the Website and may request that K7 ARC erase their personal data. Unless stated otherwise, the then-current Privacy Policy applies to all personal data K7 ARC has about users.

Notice

The material and content presented on this Website is the sole responsibility of K7 ARC, a Texas limited liability company (“we,” “our,” “us,” or the “Company”), and is qualified in its entirety by the Company’s disclosure offering statement and/or offering memorandum (the “Memorandum”), which contains more complete information including risk factors. This Website contains forward-looking statements and hypothetical economic forecasts that may not be realized. By viewing this material, you acknowledge and agree not to rely upon it in making an investment decision. This Website does not constitute or form part of any offer to sell or solicitation of an offer to buy securities, nor shall it form the basis of any contract or commitment. This material is not directed at, and does not constitute an offer or solicitation to, any person or entity who is not an “accredited investor” as defined under Rule 501(a) of the U.S. Securities Act of 1933, as amended, or who does not meet the qualifications described in the Memorandum and/or Regulation D of the U.S. Securities Act of 1933, as amended.